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Any breach of medical confidentiality is an injury to the patient. Hageman v. Sw. Gen. Health Ctr., 893 N.E.2d 153, 156 (Ohio 2008). Ohio recognizes the breach of physician-patient confidentiality as a tort, which means the plaintiff may recover for any harm suffered. Since it is considered a tort, case law controls the issue (whereas statutory law controls non-tort cases)

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